Privacy Policy
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HKCS Candidate Data Privacy Notice
Effective date: December 7, 2023
HKCS is committed to protecting and securing the privacy and confidentiality of the Personal Data which it collects directly or indirectly from you when applying for a job at HKCS or initiating an engagement with HKCS as your Client1 either directly or through a third-party human resources agency/third party service provider. This notice (the “Notice”) outlines and explains how HomeKodi Consulting And Services Private Limited including its subsidiaries, local employing2 entities, associates, and affiliated companies [collectively referred to as “HKCS”, “us,” “our”, or “we”] will process your Personal Data in accordance with applicable privacy legislation(s).
What Personal Data Do We Process?
For the purposes of this Notice, ‘Personal Data’ means any information about you from which you can be identified (whether derived from that information on its own or when combined with other information that we or another party may hold about you).
Personal Data may be either provided to us by you or the supplier/service provider you represent, or collected through a third party as part of your recruitment/engagement process with HKCS. Such Personal Data may include but is not limited to:
1)Identifying data, such as name, email address;
2)Contact details, such as postal address and telephone number;
3)Recruitment-related information, such as right to work authorisation, citizenship, date of birth, residency, previous work experience information (including previous employer references), qualifications and work history, educational background, language skills, professional skills and talents, professional membership, community engagement, geographic location preferences, and recruitment company reports (where available), salary expectations, interactions over emails, webchats, audio/video conversations; and
4)Any other Personal Data you voluntarily provide during the job application/pre-contractual relationship process for our consideration.
Special Categories of Personal Data (not applicable for third party contractors)
HKCS may process Special Categories of Personal Data such as, racial/ethnic origin, and health information, in limited circumstances and only where we are permitted to do so under applicable legislation(s). Furthermore, we may be required from time-to-time to process your Special Categories of Personal Data in order to carry out our obligation(s) and exercise our right(s) in relation to employment law or any other law as it applies to us at any given point in time. HKCS takes the protection and security of your Special Categories of Personal Data seriously, and the highest level of technical and organisational security controls are applied when we process your Special Categories of Personal Data.
Why We process your Personal Data?
We process your Personal Data for specified purposes and on the following legal grounds, for the various situations which may arise during the job application process or third-party contractual relationship with us:
1)As it may be necessary for preserving our or a Third Party’s legitimate interests (please see ‘How do We use your Personal Data?’ section below);
2)As it may be necessary for preserving our or a Third Party’s legitimate interests (please see ‘How do We use your Personal Data?’ section below);
3)As it is, or if it becomes, necessary to comply with any legal obligation(s), including but not limited to, any local law(s), to the extent of the applicability of such law(s) (e.g. conducting service provider due diligence or exercising our audit rights);
4)As is necessary to protect your vital interests when you are physically or legally incapable of giving Consent; and
5) Data Processing based on your Consent.
In exceptional circumstances you may request us to disclose your Personal Data to Third Parties or organisations such as a law firm handling a Data Subject claim on your behalf, or otherwise.
There may also be exceptional circumstances, where you may explicitly Consent to the Processing of your Personal Data, but only if the Consent is truly freely given and unambiguous e.g., Consent to publish your photograph on marketing materials.
How We Use Your Personal Data?
We process your Personal Data, for the purposes including but not limited to the ones enlisted below, via both manual and automated means. For candidates/applicants, we also use ATS (Applicant Tracking System) which stores your Personal Data once you have made an application in order to enable the relevant recruiting manager and recruiter to consider your application. We will always have human intervention in your candidacy assessment and never solely rely on Automated Decision-Making, including Profiling.
Why We Share Personal Data
Only selected employees of HKCS – such as your potential future manager(s), employees of HR and IT (for maintenance purposes only) - and selected employees of our external service providers who support us with the admission of recruitment application/third-party contractors, may have access to your Personal Data. Whenever we permit a Third Party to access Personal Data, we will make sure the data is used in a manner consistent with this Notice (and any applicable internal data handling guidelines consistent with the sensitivity and classification of the data).
Please note, in some circumstances, Third Parties may qualify as Controllers who process your Personal Data for their own purposes. Please refer to these Controllers’ privacy notices or statements. Otherwise, all Third Parties are Processors acting on the instructions of HKCS. Wherever we engage a Processor, we require assurances that such Processors have implemented appropriate safeguards and controls in relation to the protection of your Personal Data. In addition to the Third Parties’ legal obligations, we require that such Third Parties be also contractually obligated to safeguard your Personal Data. Ongoing oversight is maintained on the relevant Processing activities being carried out by the Third Party.
For applicants and candidates, if required, we may conduct background checks prior to you commencing employment/engagement with us. In order to do so, HKCS may have a requirement to share your Personal Data with the relevant Third Parties. These checks will be performed by our Processors who conduct background screening on our behalf.
How Long Do We Retain your Personal Data?
We retain your Personal Data for as long as it is necessary to fulfill the purposes for which it is processed that is for the duration of your onboarding process. Post onboarding and pre-joining/contracting formalities your data will not be kept longer than necessary for the purpose for which it was processed. For example, we may need to retain your Personal Data to comply with Tax and other Applicable Laws, for audit purposes and to exercise or defend any legal claims.
How to contact us?
Thanks for reading our Privacy Policy. If you have any questions, requests, comments, and/or concerns regarding this Privacy Policy, please contact us at the following e-mail: privacypolicy@homekodiconsulting.com